ML20138N253
| ML20138N253 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/27/1985 |
| From: | Decker T, Sartor W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138N242 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 50-348-85-37, 50-364-85-37, NUDOCS 8512230422 | |
| Download: ML20138N253 (10) | |
See also: IR 05000348/1985037
Text
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UNITED STATES
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NUCLEAR REGULATCRY COMMISSION
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REGloN 11
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101 MARIETTA STREET, N.W.-
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ATLANTA, GEORGI A 30323
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DEC i 01985
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Report Nos.: 50-348/85-37 and 50-364/85-37
. Licensee: Alabama Power Company
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-600 North 18th Street
_ Birmingham, AL 35291
.
Docket Nos.:
50-348 and 50-364
Facility Name:
Farley 1 and 2
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Inspection Conducted:
September 24-26, November 8, and November 22, 1985
Inspector: TA
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W. M. Sartor, Jr. //
Date Sfgned
. Accompanying Personnel:
K. Clark, G. Arthur, G. Weale, J. MacLellan, and
A.L. Smith-
Approved'by:
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T.'R. Decker Section Chief
Da'te S'igned
Division of Radiation Safety and Safeguards
SUMMARY
Scope _: This . routine, unannounced inspection entailed 118 inspector-hours in the
area of a small scale emergency' exercise.
,.
Results: One violation was identified in that the licensee failed to have the
capability to notify responsible State and local governmental agencies within
-15 minutes after declaring an emergency.
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8512230422 851210
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REPORT DETAILS
.1.
-Persons' Contacted
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Licensee Employees
- O.~W.lMorey, Assistant Plant Manager - Operations
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- J. W. Beckham, Director, Farley Nuclear. Plant Visitors Center
- J.lF. Holloway, Shift Supervisor
'*R. B. Wiggines, Supervisor Operation Training Section
- N. M..Maddox, Senior Plant Instructor
- R. P.' Mcdonald, Senior Vice President
- K. W. McCracken, Manager,' Nuclear Technical Support
- C.: L. Buck, Supervisor - Nuclear Engineering
- J. E.. Garlington,. Manager- Nuclear Engineering and Licensing
- J.'W. McGowan, Manager Safety Audit and Engineering
.
- W. G. Ware, Supervisor SAER Review
- T. W. Cherry, Instrumentation and Control Supervisor
.
- B. L. Moore, Unit Supervisor
- B. P. Patton, Plant Health' Physicist
- R. D. Hill, Operations Manager
-*F. N. Wade, Manager Public Communications
- L.JJ. Maier, Senior Plant Instructor -
- D.- E. Grissette, Environmental Section Supervisor
- J. B. Kelly, Environmental Technician
- F. M.'Jessup, Senior Engineer
- M. A.:Treadwell- Specialist
,
- J. R. Robinson, Health Physics Technician
J. F. Bouillon, Dosimetry Foreman
- W. T. Cooley, Training Coordinator
- P. E; Farnsworth, Health Physics Section Supervisor
.
- D
M. Varner, Manager Nuclear Administration
- T. R. Hawkins, Senior Engineer
- L. T. -Jackson, Training Sector Supervisor
.
- 0ther licensee- employees contacted- included engineers,
technicians,
operators, mechanics, security force members, and office personnel.
NRC Resident Inspectors
- W. H. Bradford
- B. Bonser
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on September' 26,1985,
with those persons indicated in paragraph 1 above. The inspector described
the areas inspected and discussed the inspection findings listed below.
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Licensee representatives stated that they did not concur with the 15-minute
notification- requirement.-and referenced the outstanding unresolved item
' addressing same -(50-348/84-26-01, 50-364/84-26-01).
On November 8,
1985,
the- issue was further ' discussed via' a
conference- call
between
- representatives . from Region II and Farley Nuclear -Plae
Following the
' discussion, Region II management personnel reviewed the issues' with NRC
Headquarters inspection and enforcement management. On November 22,.1985,
D. M. Verre111, Chief Reactor Projects Branch I at Region II notified
J. D. Noodard, Farley Nuclear Plant Manager, that a Notice-of Violation was
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-being issued.
The licensee- did not identify as proprietary any of the
materials provided to or reviewed by the inspector during this inspection.
3 .'
Licensee Action on Previous Enforcement Matters (92700).
.This subject was not addressed in the inspection.
!4-
Exercise Scenario (82301)
.
The scenario for the emergency exercise was reviewed to determine that
provisions had been made to test the integrated capability and a major
portion of the basic elements existing within the licensee, state and local
emergency plans and organization as required by 10 CFR 50.47(b)(14),
10 CFR 50, Appendix -E, paragraph IV.F and specific criteria in NUREG 0654,
Section II.N.
The scenario was reviewed in advance of the scheduled exercise date and was-
discussed with licensee representatives both by telephone and in letters
dated August 8 and September 6,1985.
As a result of the sce.nario review
the licensee augmented the scenario with contingency messages'to' ensure that
- the Emergency Operations Facility (EOF) staff's dose assessment capability
and engineering support capability could be adequately exercised. Addi-
tionally, the EOF dose assessment staff was pre positioned in Dothan such
that they could arrive at the site and demonstrate dose rate projection and
plume tracking capability independent of the Technical Support Center (TSC)
staff during the period of the effluent release.
No violations or deviations were identified.
.
5.
Assignment of Responsibility (82301)
This area was observed to determine that primary responsibilities for
emergency response by the licensee were specifically established and that
adequate staff was available to respond to an emergency as required by
- 10 CFR 50.47(b)(1),10 CFR 50, Appendix E, paragraph IV.A, and specific
criteria in NUREG 0654,Section II.A.
.The inspectors observed that specific emergency assignments had been made
for-the licensee's emergency response organization. Adequate staff was
available to respond to the simulated emergency.
The initial response
organization was augmented by designated licensee representatives and
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planning for - long term or. continuous staffing .of the emergency response
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. organization _was demonstrated.
No violations or: deviations were identified.
- 6.
-Onsite' Emergency Organization (82301)
.
= iThs licensee's onsite emergency organization was observed to determine that
'the' responsibilities for emergency response were unambiguously defined, that-
- adequate. staffing _ was provided to insure initial facility accident response
in' key functional areas at all times, and that the interfaces were specified -
. as required by - 10 CFR 50.47(b)(2),10 CFR 50, Appendix E, paragraph IV. A,
andLspecific' criteria in NUREG 0654,Section II.B.
The inspectors determined that the licensee's onsite emergency organization
was effective in dealing with'the simulated emergency. Adequate staffing of
Lthe emergency response facilities was provided for the initial accident
response and~the interfaces between the onsite organization and the limited
participating offsite support agencies appeared to be adequate. ~Although
the responsibilities for emergency response appeared to be unambiguously
defined, it was not apparent when responsibilities were transferred to the
Emergency Director from the shift supervisor. When the EOF was staffed, it
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was again
not : apparent as
to when
responsibilities
and which
responsibilities were transferred from the Emergency Director in the TSC to-
the Emergency Coordinator in the EOF.
No violations or deviations were identified.
J7.
Emergency. Response Support and Resources (82301)
.This. area was observed to determine that arrangements for requesting;and
- effectively using assistance resources had been made, that arrangements to
accommodate State and - local staff at the licensee's near-site Emergency
Operations Facility had been made, and that other organizations capable of-
augmenting the planned response had been identified as required by
l'0 CFR 50.47(b)(3),10 CFR 50, Appendix E, paragraph IV. A, and specific
criteria in NUREG 0654,Section II.C.
State - and local staff could have been accommodated at the near-site
Emergency Operations Facility. Licensee contact with offsite organizations
was limited in this small scale exercise.
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'No violations or' deviations were identified.
8.
Emergency Classification System (82301)
This area was observed to determine that a standard emergency classification
and action level scheme was in use by the nuclear facility licensee as
required by 10 CFR 50.47(b)(4),10 CFR 50, Appendix E, paragraph IV.C, and
specific criteria in NUREG 0654,Section II.D.
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An inspector observed that the emergency classification system was in effect
as stated in the Radiological Emergency Plan and in the Implementing Proce-
'dures. The system appeared to be adequate for the classification of the
simulated accident.
No violations or deviations were identified.
9.
Notification Methods _and Procedures (82301)
This area was observed to determine that procedures had been established for
notification by the licensee of State -and local response organizations and
emergency personnel, and that the content of initial and followup messages
to response organizations had been established; and means to provide early
notification to the populace within the plume exposure pathway had been
established as required by 10 CFR 50.47(b)(5)', 10 CFR 50, Appendix E,
paragraph IV.0, and specific criteria in NUREG 0654,Section II.E.
An inspector reviewed the notification methods and procedures established by
the licensee to provide information to Federal, State and the licensee's
augmented emergency response organization.
During the exercise, the
inspector observed that the
initial
notification of an emergency
classification to the Alabama Bureau of Radiological Health and the Georgia
Emergency Management Agency was not completed until approximately 25 minutes
after the emergency declaration.
This notification failed to meet the
standard of 10 CFR 50, Appendix E, Section IV.D.3 which specifies that the
licensee have the capability to notify responsible State and local
governmental agencies within 15 minutes after declaring an e,mergency. This
failure to make the notifications within 15 minutes to the States of Alabama
and Georgia was also observed in the 1984 Farley Emergency Exercise
-(reference Inspection Report Nos. 50-348/84-30 and 50-364/84-30). There was
an unresolved item addressing prompt notification from a previous inspection
report (50-348/84-26, 50-364/84-26) which was based on the finding that the
licensee did not have procedures requiring notification of offsite
authorities within 15 minutes of declaring the emergency, except for a
General Emergency, and likewise did not train the staff to make such
notifications except for General Emergencies.
The licensee stated that
their understanding of 10 CFR 50, Appendix E was that the capability to
notify State and local governmental agencies within 15 minutes was fulfilled
by the existence of the communication equipment.
The issue was left
unresolved pending further review by NRC. The unresolved item has now been
determined to be a violation in that:
1.
The licensee's Emergency Plan does not specify that the Emergency
Director, in the event of an emergency, is to make required
notifications within 15 minutes to the States of Alabama and
2.
Licensee's
notification
procedure
FNP-0-EIP-26,
Offsite
Notification, does not specify the 15-minute time requirement for
notifying responsible State and local response organizations
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following ' declaration ~ of . Unusual Event, Alert and Site ' Area
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Emergency classifications.
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3. -- straining records, interviews with training . program personnel and .
selected emergency organization personne) revealed that the
licensee's: ~ training program did not address notification time
constraints to offsite response organizations.
These . findings are' identified as ~ a violation of 10 CFR 50.54(q) which
requires licensees -_to follow. and maintain in effect emergency plans. which
meet _the standards of_10 CFR 50.47(b) and 10 CFR, Appendix E.
110 CFR 50.47(b)(5)- requires that ' the licensee's emergency plan includes
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' provisions for notification of State and local response organizations; and
10 CFR 50, Appendix E, Section IV.D.3 specifies that the licensee have the
capability to ~ notify _ responsible State and local governmental agencies
within
15 .-minutes
after
declaration
of
an
emergency
(50-348/85-37-01,50-364/85-37-01).
An inspector observed the content of initial and followup notifications
and/or messages provided to offsite authorities, and noted the initial
. notification of the Site Area Emergency to the States of Alat.;ma and Georgia
-was not made _ in accordance with the Farley Emergency Plan.
Specifically,
Section VI.A of the plan requires the initial message to contain as a
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minimum:
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1.
Class of Emergency
2.
Actual-or potential release information
3.
cPotentially affected population
'4.
-Advisability of protective measures
Contrary to.this requirement, the communicator providing the initial notifi-
cation gave _ only - the class of emergency although more information was
available from the . Emergency Di recto'r.
This ' failure to make offsite
notification :in accordance with the Emergency Plan is identified as an
exercise weakness and will be reviewed during subsequent inspections.
~(50-348/85-37-02,364/85-37-02).
One violation was identified.
10.
Emergency Communications (82301)
This area was observed to determine that provisions existed for prompt
communications among principal response organization and emergency personnel
' as required by 10 CFR 50.47(b)(6),10 CFR 50, Appendix E, paragraph IV.E,
and specific. criteria in NUREG 0654,Section II.F.
- Communications among the licensee's emergency response facilities
and
between the licensee's emergency response organization and offsite
authorities were adequate with one noted exception.
Specifically, the
Recovery Manager was not
informed of
the
Emergency Director's
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reclassification of the. Site Area tmergency to an Alert until 16 minutes
af ter1 the reclassification had been announced over the Emergency News
Network (ENN). 'This exercise weakness was identified by the licensee as a'
'need to make provisions to ensure that the Recovery Manager is notified of
all_ significant- ENN announcements including those originating from the TSC.
- Licensee corrective action on this exercise weakness will be reviewed during
-subsequent inspections (50-348, 364/85-37-03).
No violations or deviations were identified.
.11.
Public Education and Information (82301)
This area was observed ;to determine that information concerning the
simulated emergency was made available for dissemination to the public as
required by 10 CFR 50.47(b)(7),10 CFR 50, Appendix E, paragraph IV.D, and
specific criteria in NUREG 0654,Section II.G.
Information was provided -to the media and the public in advance of the
exercise. The licensee established a near-site Emergency News Center (ENC)
and provided accurate and timely news information that was properly
coordinated. It appeared that the primary telephone response point for tne
news media would be'better located at the near-site ENC rather than from the
company's. Birmingham headquarters. A rumor control program was in place and
extensively exercised by the licensee.
No violations or deviations were identified.
12.
Emergency' Facilities and Equipment (82301)
This area was observed to determine that adequate emergency facilities and
equipment to support an emergency response were provided and maintained as
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required by 10 CFR 50.47(b)(8),10 CFR 50, Appendix E, paragraph IV.E, .and
specific criteria in NUREG 0654,Section II.H.
The; inspectors observed this activation, staffing and operation of the
emergency response facilities and evaluated equipment provided for emergency
use during the exercise.
a.
Control Room - An inspector observed that control room personnel acted
promptly to initiate emergency response to the simulated emergency.
Emergency procedures were readily available and the response was prompt
and effective.
b.
Technical Support Center (TSC) - The TSC was activated and staffed
promptly upon notification by the Emergency Director of the simulated
emergency conditions.
The TSC staff appeared to be knowledgeable
concerning their emergency responsibilities, however status boards were
either not maintained or inadequately maintained to provide timely and
accurate information.
The Emergency Director did not routinely brief
the TSC personnel nor were site personnel kept informed of significant
plant events.
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c.
Operations Support Center _(OSC) - The OSC was staffed promptly upon
activation by the Emergency Director. An inspector observed that. teams
.were formed promptly, briefed and dispatched efficiently.
No status
boards were~ available for OSC personnel information. A Post Accident
-Sampling' System (PASS) sample was obtained under normal operating level
conditions.
- d.
Emergency Operations Facility - The EOF was located in the Training
Building at the reactor site. The facility appeared to be adequately
designed, equipped and staffed to support an . emergency response. The
EOF staff arrived onsite at 1116 hours0.0129 days <br />0.31 hours <br />0.00185 weeks <br />4.24638e-4 months <br /> and assumed the responsibilities
of the radiological monitoring teams at 1232-hours.
.m.
No violations or deviations were identified.
13 '. . Accident Assessment (82301)
This area was observed to determine that adequate methods, systems and
equipment for assessing and monitoring actual or potential offsite
consequences of a radiological emergency condition were in use as required
by 10 CFR 50.47(b)(9),10 CFR 50, Appendix E, paragraph IV.B, and specific
criteria,in NUREG 0654,Section II I.
The accident assessment program included both an engineering assessment of
plant status and an assessment of radiological hazards to onsite and offsite
personnel resulting from the accident. 'During the exercise, the engineering
accident -assessment team ' functioned effectively in analyzing the plant
status so as to make recommendations to the Emergency Director concerning
mitigating actions 'to reduce damage to plant equipment, to prevent release
of radioactive materials and to terminate the emergency condition.
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~ Radiological assessment activities involved several groups. A group in the
TSC effectively estimated the radiological impact in the plant based on
inplant monitoring and onsite measurements. Radiological effluent data was
received in the'TSC. Because the EOF staff activated after the effluent
release, the EOF dose assessment personnel were pre positioned and indepen-
dently' demonstrated dose rate projection and plume tracking capability. An
inspector noted that plant personnel provided a cadre for the corporate dose
assessment personnel and that the basis of this was not included in the
emergency implementing procedures. This exercise weakness was also noted by
. the licensee and the incort oration of the Safety Audit and Engineering
personnel to provide EOF dose assessment support into appropriate imple-
menting procedures will be reviewed during a subsequent exercise.
.(50-348/85-37-04,364/85-37-04).
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No violations or deviations were identified.
14.
Protective Responses (82301)
This ' area was observed to determine that guidelines for protective actions
during the emergency, consistent with Federal Guidance, were developed and
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in place, and protective actions for emergency workers, including evacuation
of nonessential personnel, were implemented promptly as required by
10 CFR 50.47(b)(10), and specific criteria in NUREG 0654,Section II.J.
The simulated accident did not necessitate protective action recommendations
for - of fsite . populations. However, it was noted that no protective actions
were taken onsite during and following plume passage.
The licensee also
identified E his exercise weakness and recommended reviewing training and
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procedures to ensure adequate consideration is given during emergencies to
contamination control and employee radiological protection necessary due to
_ plume passage or deposition outside the Radiation Control Area.
Licensee
corrective action will be reviewed in a subsequent inspection.
(50-348/85-37-05,364/85-37-05)
No violations or deviations were identified.
15.
Radiological Exposure Control (82301)
This area was observed to determine that means for controlling radiological
exposures, in an emergency, were established and implemented for emergency
workers and that they included exposure guidelines consistent with EPA
recommendations as required by 10 CFR 50.47(b)(11), and specific criteria in
An inspector noted that radiological exposures were controlled throughout
the exercise by issuing emergency workers supplemental dosimeters and by
periodic surveys in the emergency response facilities. Exposure guidelines
were in place for various categories of emergency actions and adequate
protective clothing and respiratory protection were available and used as
appropriate. Although habitability checks were routinely conducted in the
EOF, no habitability checks were observed in the control room, TSC, and the
Operations Support Center.
No violations or deviations were identified.
16.
Exercise Critique (82301)
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The licensee's critique of the emergency exercise was observed to determine
that deficiencies identified as a result of the exercise and weaknesses
noted in the licensee's emergency response organization were formally
presented to licensee management for corrective actions as required by
10 CFR 50.47(b)(14),10 CFR 50, Appendix E, paragraph IV.E, and specific
criteria in NUREG-0654,Section II.N.
A formal licensee critique of the emergency exercise was held on
September 26, 1985, with exercise controllers, key exercise participants,
licensee management and NRC personnel attending.
Many but not all of the
weaknesses in the emergency preparedness program, identified as a result of
this exercise were presented by the licensee. NRC also presented a summary
of exercise findings.
Followup of corrective actions will be accomplished
through subsequent NRC inspections.
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1.17.
Inspector Followup (92701).
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. (Closed) The' previous unresolved item (50-348,364/84-26-01)- addres. sing the
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. failure of:the; licensee. to develop and' fully use required prcnot notifica -
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tion Jcapability: for emergency action classification i s closed -and
. reclassified
.as _a
violation -(50-348/85-03-01,364/85-37-01).
See
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.-paragraph-9 of-this. report.
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